Documente Academic
Documente Profesional
Documente Cultură
-versus-
ON
KEN D. LANDI
ABC360 FOODS, INC.,
Defendants
x-----------------------------------x
COMPLAINT FOR DAMAGES
Plaintiffs thru counsel, and unto this Honorable Court, respectfully
manifest:
1. That plaintiff Ella L. Nager is of age, married, and resides at No. 75
Camp 7, Baguio City; while plaintiff Ishani Langanda is also of age,
married, and resides at No. 45 Bakakeng Sur, Baguio City;
2. That defendant ABC360 Foods, Inc. is a corporation duly organized
under Philippine law, engaged in the business of manufacturing food
products with principal office at the Puso ng Baguio Building, Session
Road, Baguio City; while the other defendant Ken D. Landi is the driver
of the corporations delivery panel or truck, and both may be served
with summons at said Puso ng Baguio Building.
3. That for cause of action against the defendants, it is hereby stated that
on or about December 14, 2013, at about eight oclock in the morning,
while driver Ken D. Landi was operating the companys delivery panel
or truck, bearing plate number ACY 247 along Bonifacio Road, within
the territorial jurisdiction of Baguio City, he so negligently and
recklessly operated it at a fast speed in disregard of traffic conditions
then existing that he causes it to bump with terrific force against a
Honda Civic model 2010 bearing plate number ILY 143 in which
plaintiffs were in;
4. That because of the terrific impact, the said Honda Civic was greatly
damaged, not only in the rear portion but also in its front or radiator
1. Actual
damages
of
SEVENTY
THOUSAND
PESOS
(P70,000.00);
2. Moral damages of FIFTY THOUSAND PESOS (P50,000.00);
3. Attorneys Fees of FIFTY THOUSAND PESOS (P50,000.00).
b. To Ishani Langanda:
1. Actual damages of THREE HUNDRED THOUSAND PESOS
(P300,000.00)
2. Loss of profits of ONE HUNDRED THOUSAND PESOS
(P100,000.00);
3. Attorneys Fees of FIFTY THOUSAND PESOS (P50,000.00).
or total damages for both plaintiffs in the sum of SIX HUNDRED TWENTY
THOUSAND PESOS (P620,000.00), with legal interest from the date of filing
this suit, plus costs of suit, and such other remedies as may be just and
equitable in the premises.
All other just and equitable reliefs are also prayed for.
Baguio City, Philippines, this 8th of day September, 2014.
MC RHONDOLF LOUIE V. MABALOT
Counsel For Petitioners
No. 143 Brgy. New Lucban, Baguio City
IBP Lifetime No.2080203; Baguio City
PTR No. 2080203; July 14, 2014, Baguio City
Roll of Attorney No. 2080203
MCLE Compliance No. 1111111
ELLA L. NAGER
ISHANI LANGANDA
Ishani Langanda
Doc. No. 2
Page No. 1
Book No. I
Series of 201